Deviation reporting: what to capture while it's fresh

Deviations are broader than exceedances

A deviation is any failure to meet a permit term or applicable requirement, not just an emission limit exceedance. Missed monitoring, a late record, a control device operating outside its parameter range, or a skipped inspection can all be deviations. Part 63 defines the term at 40 CFR 63.2, and your permit may define it too.

Prompt reporting and periodic reporting

Title V permits require prompt reporting of deviations, including the probable cause and any corrective actions or preventive measures taken (40 CFR 70.6(a)(3)(iii)(B)). The permit defines what “prompt” means, often differently for different kinds of deviations. The periodic monitoring report must then identify all deviations in the period, and the annual compliance certification reflects them.

State upset, malfunction, or excess emissions rules can add separate notification and reporting requirements with their own timelines. Check them alongside the permit.

Record these on the day

Details fade fast. Capture them while operators still remember:

• Start and end date and time, and how the deviation was discovered
• The emission unit and the exact permit condition or rule affected
• What happened, in plain words, and what operators observed
• Probable cause, and whether it could recur
• Corrective actions and preventive measures, with dates
• Pollutants involved and an excess emissions estimate with its basis
• Who was notified, how, and when, including any prompt report

Close the loop

Track each deviation until the corrective action is complete, and look across the period for repeats. The same cause showing up twice is a maintenance or procedure problem to fix, and agencies notice repeat deviations.